Part VII, Subpart i, Chapter 1, Section AGeneral Information on Relationship and Dependency

Revised February 15, 2022

VII.i.1.A.1.a#Definition: Relationship

The term relationship refers to an individual’s legal status with respect to the Veteran. Examples:

• Can the individual be recognized as the Veteran’s child?
• Have the individual and the Veteran fulfilled the requirements for a legal marriage?

References: For a definition of

• spouse, see 38 CFR 3.50
• child, see 38 CFR 3.57, and
• parent, see 38 CFR 3.59.

VII.i.1.A.1.b#Definition: Dependency

The term dependency refers to the question of whether or not an individual relies on a Veteran for financial support.

VII.i.1.A.1.c#Importance of Establishing the Relationship of an Individual to a Veteran

Establishing an individual’s relationship to a Veteran is critical because

• the Department of Veterans Affairs (VA) may pay additional disability compensation to a Veteran for dependent(s) if the Veteran’s service-connected (SC) disability rating is at least 30 percent
• VA may pay additional Dependency and Indemnity Compensation (DIC) to a surviving spouse for children that VA recognizes as a child of the Veteran on whose death the DIC award is based
• the existence and the amount of income of dependents is a factor in determining entitlement in both Veterans Pension and Survivors Pension cases, and
• a claimant’s entitlement to survivors benefits, such as DIC and Survivors Pension, is contingent on the relationship of the claimant to the Veteran on whose death the benefit is based.

References: For more information on

• claims processor responsibilities
  • when promulgating a rating decision that assigns an overall SC disability rating of at least 30 percent to a Veteran whose overall SC disability rating prior to the rating decision was less than 30 percent, see M21-1, Part VII, Subpart i, 1.C.1.b, and
  • each time the rating activity assigns an overall SC disability rating of at least 30 percent, see M21-1, Part VII, Subpart i, 1.C.1.e
• establishing the existence of a familial relationship between a Veteran and another individual, see 38 CFR 3.50 through 38 CFR 3.60
• the payment of additional
  • disability compensation for dependents, see 38 CFR 3.4(b)(2), and
  • DIC for children of a deceased Veteran, see 38 CFR 3.10(e)(1), and
• establishing an individual as a Veteran’s parent, see M21-1, Part VII, Subpart i, 4.A.

VII.i.1.A.1.d#Circumstances Under Which VA Assumes Financial Dependency Exists

Once VA determines a marital relationship exists between a Veteran and spouse, VA assumes the spouse is financially dependent on the Veteran. Similarly, once VA establishes that an individual is the child of a Veteran, VA assumes the child is financially dependent on the Veteran. VA does not require proof of financial dependency under either of these circumstances. References: For more information on

• determining whether a marital relationship exists, see
  • M21-1, Part VII, Subpart i, 2.A
  • 38 CFR 3.50 (spouse and surviving spouse)
  • 38 CFR 3.52 (marriages deemed valid)
  • 38 CFR 3.53 (continuous cohabitation)
  • 38 CFR 3.54 (marriage dates), and
  • 38 CFR 3.55 (reinstatement of a surviving spouse’s eligibility based on termination of a marital relationship), and
• determining whether an individual is the child of a Veteran, see
  • M21-1, Part VII, Subpart i, 3.A
  • 38 CFR 3.57, and
  • 38 CFR 3.58 (child adopted out of the family).

VII.i.1.A.1.e#Circumstances Under Which VA Requires Proof of Financial Dependency

VA requires proof of financial dependency in order to pay

• additional compensation for a parent to a Veteran whose SC disability rating is at least 30-percent, or
• DIC to the parent of a Veteran whose death was service-related.

References: For more information on determining whether

• an individual is the parent of a Veteran, see
  • M21-1, Part VII, Subpart i, 4.A, and
  • 38 CFR 3.59, and
• the parent of a Veteran is financially dependent on the Veteran, see M21-1, Part VII, Subpart i, 4.B.

VII.i.1.A.1.f#Considering the Existence of Dependents When Determining Entitlement to Disability and Survivors Benefits

The existence of dependents is not a factor in determining entitlement to disability compensation or DIC. However, the existence of dependents is a factor in determining entitlement to pension. Persons who claim entitlement to income-based benefits must report all dependents and dependent's income and net worth. When VA receives a claim for pension, claims processors must follow the instructions in M21-1, Part VII, Subpart i, 1.A.6, during the initial development phase , if any of the following is missing:

• information regarding the number of dependents a claimant has
• evidence or information required to establish the existence of a familial relationship between a Veteran and a dependent(s), and/or
• each dependent’s income and net worth.

Reference: For more information on considering the income of dependents when determining entitlement to pension, see

• 38 CFR 3.23(d)(4), and
• 38 CFR 3.24.

VII.i.1.A.1.g#Handling Claims for Benefits for or From an Individual That VA Does Not Recognize as a Veteran’s Dependent

If a claimant lacks status as the dependent of a Veteran for VA purposes , deny the claim without further development. Similarly, deny a claim from a Veteran or surviving spouse for additional benefits for an individual whom VA cannot recognize as the dependent of a Veteran for VA purposes. Examples:

• A deceased Veteran’s grandchild, whom the Veteran never adopted, claims entitlement to VA survivor’s benefits.
• A Veteran claims entitlement to additional benefits for a foster child.

Reference: For more information on individuals whom VA may recognize as a Veteran’s dependent, see

• M21-1, Part VII, Subpart i, 1.A.1.a, and
• O’Brien v. Wilkie, 30 Vet.App. 21 (2018).

VII.i.1.A.1.h#Interplay Between Federal, State, and Foreign Laws

VA benefit programs are authorized by Federal law (38 U.S.C.) that determines who is and who is not eligible for benefits. Some of the rules concerning VA’s recognition of a familial relationship between a Veteran and another individual are unique to VA benefit programs. Example: The continuous cohabitation requirement of 38 CFR 3.53. In many instances, VA incorporates State law or the law of foreign countries by reference. When making decisions on the issue of relationship, State law is relevant only to the extent that it is incorporated by reference into the body of Federal law governing VA eligibility determinations. Example: 38 CFR 3.1(j) refers to local law for determining the basic validity of a marriage. Note: When a determination regarding the validity of a marriage depends on whether a prior marriage ended before the date of the current marriage, see the document titled Divorce Effective Date Table on Compensation Service’s Job Aids webpage.

VII.i.1.A.1.i#Duty of Claimants to Report Familial Relationships and Family Composition

Family composition is determined objectively under applicable VA regulations. Claimants must accurately report familial relationships and family compositions when requested to do so by VA. Claimants seeking entitlement to disability compensation or DIC have the option of claiming or not claiming dependents. However, claimants seeking entitlement to any of VA’s income-based benefits must

• report all dependents and dependent's income, and
• not manipulate family composition to maximize benefits.

Example: Failure of a pension claimant to report a spouse with income or substantial assets would be considered manipulation to maximize benefits.

2Burden of Proof and the Weighing of Evidence

This topic contains information on a claimant’s burden of proof and the weighing of evidence, including

• responsibilities of VA and claimants for securing evidence
• accepting entries a claimant makes on VA Form 21-686c, Application Request to Add and/or Remove Dependents , as proof of an event, and
• evaluating and weighing evidence.

Revised December 15, 2017

VII.i.1.A.2.a#Responsibilities of VA and Claimants for Securing Evidence

VA must make reasonable efforts to assist a claimant in securing evidence, but the claimant always has the initial burden of proof. This means that unless the claimant furnishes evidence on each element needed to establish the point at issue, VA must deny the claim. Example: A claimant alleging the existence of a deemed-valid marriage must meet the requirements in 38 CFR 3.52 to establish the marriage as valid for VA purposes. If no evidence is provided showing the claimant meets those requirements, VA must deny the claim. Nevertheless, VA may, because of its duty to assist, provide reasonable assistance to secure the evidence. References: For more information on

• VA’s duty to assist in developing claims, see
  • M21-1, Part I, Subpart i, 1.A
  • M21-1, Part III, Subpart i, 2.A.1, and
  • 38 CFR 3.159, and
• the requirements for establishing a deemed-valid marriage, see M21-1, Part VII, Subpart i, 2.D.7-10.

VII.i.1.A.2.b#Accepting Entries a Claimant Makes on VA Form 21-686c as Proof of an Event

Except as noted in 38 CFR 3.204(a)(2), VA will accept the entries a claimant or beneficiary makes on VA Form 21-686c, Application Request to Add and/or Remove Dependents, as sufficient proof of

• marriage
• dissolution of a marriage
• birth of a child
• introduction of a stepchild into a Veteran’s family, or
• death of a dependent.

Notes:

• Unless there are inconsistencies in a claimant’s statement, the policy described in the above paragraph allows regional offices (ROs) to establish the existence of a familial relationship between a Veteran and another individual without reviewing the claims folder.
• It is appropriate to request further evidence from a claimant if there is substantial reason to challenge the entries on VA Form 21-686c. (A substantial reason is something beyond mere suspicion or doubt.)

VII.i.1.A.2.c#Evaluating and Weighing Evidence

Once all procurable evidence is of record, claims processors must

• evaluate the competency, credibility, and persuasiveness of the evidence, and
• determine if the competent and credible evidence in favor of the claimant’s position is of equal or greater weight than the evidence to the contrary.

Use the table below to determine whether or not a point is established.

Reference: For more information on adding a dependent to the award of a Veteran entitled to disability compensation, see M21-1, Part VII, Subpart i, 1.C.1 and 2.

3Jurisdiction Over Relationship Determinations

This topic explains who has jurisdiction over relationship determinations, including

• jurisdiction over questions involving facts
• who has the authority to resolve issues involving relationship and dependency
• when administrative decisions are required
• when ROs must request an opinion from District Counsel, and
• procedure for submitting a request for an opinion to District Counsel.

Revised August 29, 2025

VII.i.1.A.3.a#Jurisdiction Over Questions Involving Facts

The authorization activity has exclusive jurisdiction over questions involving facts of relationship or dependency. Questions of fact differ from questions requiring the interpretation of law. Example: The issue of whether Bob was below the age of majority when married to Linda is a question of fact. The issue of whether Bob being underage renders the marriage void is a question of law.

VII.i.1.A.3.b#Who Has the Authority to Resolve Issues Involving Relationship and Dependency

The authorization activity has the authority to resolve issues involving relationship and dependency without District Counsel input if

• there is no doubt as to the legal effect of the facts found
• it is apparent that the case in question is identical to an existing District Counsel or Office of General Counsel (OGC) opinion, or
• the case in question is not identical, but the facts and questions of law involved are substantially the same with respect to material facts and controlling legal principles as an existing District Counsel or OGC opinion.

VII.i.1.A.3.c#When Administrative Decisions Are Required

The table below lists issues involving relationship or dependency that require resolution through an administrative decision.

__

Notes :

• The preceding list is not all-inclusive. Other issues may arise that require resolution by administrative decision.
• All administrative decisions require two signatures unless otherwise indicated.

Reference: For more information on administrative decisions, see M21-1, Part X, Subpart v, 1.C.1.

VII.i.1.A.3.d#When ROs Must Request an Opinion From District Counsel

The table below contains a description of situations in which ROs must request an opinion from District Counsel.

VII.i.1.A.3.e#Procedure for Submitting a Request for an Opinion to District Counsel

The table below contains instructions for submitting a request for an opinion to District Counsel.

4Handling Notices and Claims From Beneficiaries and Claimants Regarding Dependents

This topic contains instructions for handling notices and claims from beneficiaries and claimants regarding dependents, including

• forms claimants must use to initiate the process of adding a dependent
• controlling claims for additional compensation for a dependent
• claims from Veterans with an overall disability rating that is less than 30 percent
• handling a form that contains conflicting information
• incomplete forms and claims requiring additional evidence/information
• action to take upon receipt of a request to add a dependent that was not submitted on a prescribed form
• notification from a beneficiary that will result in removal of a dependent from the beneficiary’s award
• possible retroactive restoration of benefits
• acceptability of VA Form 21-686c from a VA-recognized representative, and
• acceptability of a VA Form 21-686c or VA Form 21-674, Request for Approval of School Attendance , that an RO or call center employee completes and signs.

Revised February 15, 2022

VII.i.1.A.4.a#Forms Claimants Must Use to Initiate the Process of Adding a Dependent

Effective March 24, 2015, a claimant must submit VA Form 21-686c or one of the prescribed forms listed in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, to initiate the process of adding a dependent to the award. Follow the instructions in M21-1, Part VII, Subpart i, 1.A.4.f if a claimant submits a request to add a dependent using anything other than a prescribed form.References: For more information on

• the authority of VA-recognized representatives to submit VA Form 21-686c on a claimant’s behalf, see M21-1, Part VII, Subpart i, 1.A.4.i, and
• adding a dependent to an award of
  • disability compensation, see M21-1, Part VII, Subpart i, 1.C.1 and 2
  • pension, see M21-1, Part IX, Subpart iii, 1.F.1 and 2, and
  • DIC, see M21-1, Part XII, Subpart i, 3.A.

VII.i.1.A.4.b#Controlling Claims for Additional Compensation for a Dependent

When VA receives one of the prescribed forms listed in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, that is substantially complete, follow the instructions in M21-1, Part III, Subpart i, 2.F.2.a, for adding d ependency claim for [insert name of dependent] as a contention for each dependent the Veteran is claiming. Note: When adding d ependency _claim for [insert name of dependent] _as a contention, select No in the MEDICAL field, and select the Administrative Issue option from the drop-down menu next to the CLASSIFICATION field. Follow the additional instructions in the table below when VA receives a claim for additional compensation for a dependent(s) in conjunction with or while a claim for service connection (SC) and/or a higher disability rating is pending.

References: For more information on

• handling forms that are not substantially complete, see Steps 2 through 9 of the table in M21-1, Part VII, Subpart i, 1.A.5.d, and

• the Veterans Benefits Management System (VBMS), see the VBMS Core User Guide.

VII.i.1.A.4.c#Claims From Veterans With an Overall Disability Rating That Is Less Than 30 Percent

Follow the instructions in the table below when a Veteran with an overall SC disability rating that is less than 30 percent files a claim for additional compensation for a dependent(s).

Exception: Disregard the instructions in the table above if a rating EP is currently pending. In this case, postpone a decision on the claim for additional compensation for a dependent(s) until after the rating activity makes its decision. (The Rules-Based Processing System (RBPS) currently makes no accommodation for this exception.)

References: For more information on

• controlling claims for additional compensation for a dependent(s) when a rating EP is concurrently pending, see M21-1, Part VII, Subpart i, 1.A.4.b
• RBPS, see M21-1, Part VII, Subpart i, 1.D, and
• requests for an application, see M21-1, Part II, Subpart iii, 2.G.1.

VII.i.1.A.4.d#Handling a Form That Contains Conflicting Information

If one of the forms in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, is complete but contains information that conflicts with other evidence of record, attempt to obtain clarification by telephone. If efforts to obtain clarification by telephone are unsuccessful ,

• follow the instructions in M21-1, Part III, Subpart i, 2.D.1.e, for documenting the unsuccessful attempt, and
• use the table below to determine the next action(s) to take.

VII.i.1.A.4.e#Incomplete Forms and Claims Requiring Additional Evidence/Information

If a claimant submits one of the forms in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, and the form is incomplete or VA requires additional evidence/information in order to grant the claim, follow the instructions in

• M21-1, Part VII, Subpart i, 1.A.5, if the benefit is disability compensation or DIC, or
• M21-1, Part VII, Subpart i, 1.A.6, if the benefit is pension.

VII.i.1.A.4.f#Action to Take Upon Receipt of a Request to Add a Dependent That Was Not Submitted on a Prescribed Form

If a claimant submits a request to add a dependent but fails to use one of the forms referenced in M21-1, Part II, Subpart iii, 1.A.1.a, first attempt to contact the claimant by telephone for the purpose of completing VA Form 21-686c and/or VA Form 21-674, Request for Approval of School Attendance, on the claimant’s behalf. If attempts to contact the claimant by telephone are unsuccessful, follow the instructions in M21-1, Part II, Subpart iii, 2.G.1.a. Reference: For more information on the authority of RO employees to complete and sign VA Form 21-686c and VA Form 21-674 on a claimant’s behalf, see M21-1, Part VII, Subpart i, 1.A.4.j.

VII.i.1.A.4.g#Notification From a Beneficiary That Will Result in Removal of a Dependent From the Beneficiary’s Award

VA does not require beneficiaries to use a specific form to report a change in a dependent’s status that will result in removal of the dependent from the beneficiary’s award. A beneficiary may report such changes

• in writing
• by telephone or e-mail, or
• through a VA claims-submission service website.

When a beneficiary requests removal of a dependent, the beneficiary must, at a minimum, provide VA with the date (month, day, and year) of the event (such as death or marriage of a child) that necessitates such action. If the beneficiary fails to provide this information, follow the instructions in M21-1, Part VII, Subpart i, 1.C.4.e. Important:

• If a beneficiary does not provide the location of the event that necessitates removal of a dependent from the beneficiary’s award, follow the instructions in M21-1, Part VII, Subpart i, 1.C.4.e.
• VA employees must follow the instructions in M21-1, Part III, Subpart i, 2.D.1.f when obtaining an oral statement (such as a statement obtained by telephone) from a claimant or beneficiary.
• If an employee receives a statement from a beneficiary over the telephone that will reduce the beneficiary’s award, and the employee fails to properly identify the beneficiary, VA must provide the beneficiary due process before reducing the award.

References: For more information on

• due process and the requirement to provide notice of proposed adverse action, see M21-1, Part X, Subpart ii, 3.A, and
• adjusting benefits based on the loss of a dependent, see M21-1, Part VII, Subpart i, 1.C.4.

VII.i.1.A.4.h#Possible Retroactive Restoration of Benefits

Per 38 CFR 3.103(b)(4), VA retroactively restores benefits it reduced, discontinued or otherwise adversely affected based on information it obtained orally if, within 30 days of the date VA issued the notice of adverse action, the beneficiary or the fiduciary asserts that the adverse action was based upon information or statements that were

• inaccurate, or
• not provided by the beneficiary or the fiduciary.

Note: Restoration of benefits under 38 CFR 3.103(b)(4) will not preclude VA from taking subsequent action that adversely affects benefits.

VII.i.1.A.4.i#Acceptability of VA Form 21-686c From a VA-Recognized Representative

38 CFR 3.160(a)(2) allows VA to accept a VA Form 21-686c that a VA-recognized representative (power of attorney or employee of a Veterans service organization) completes, signs, and submits to VA on a claimant’s behalf as if submitted by the claimant. Important:

• If information a representative provides on VA Form 21-686c will result in a reduction or discontinuance of benefits, VA must
  • attempt to contact the beneficiary by telephone to confirm the entries the representative made on the form, and
  • document the attempt(s) according to the instructions in M21-1, Part III, Subpart i, 2.D.1.e.
• If attempts to contact the beneficiary by telephone are unsuccessful , VA must provide the beneficiary with notice of proposed adverse action before reducing/discontinuing benefits.

Rationale: The beneficiary’s representative is considered a “third-party” for the purpose of determining whether VA must offer the beneficiary due process before making an adverse adjustment to the award based on information VA obtained from the representative. Reference: For more information on due process and the requirement to issue notice of proposed adverse action, see M21-1, Part X, Subpart ii, 3.A.

VII.i.1.A.4.j#Acceptability of a VA Form 21-686c or VA Form 21-674 That an RO or Call Center Employee Completes and Signs

VA authorizes its RO and call center employees to

• complete VA Form 21-686c and VA Form 21-674, using information obtained from a claimant over the telephone, and
• sign the form on the claimant’s behalf.

Note: The form must include clear identification of the employee executing the form through a digital signature or, when electronic submission is not available, a wet signature. Important:

• Treat a VA Form 21-686c or VA Form 21-674 that an RO or call center employee completes and signs on a claimant’s behalf as valid and direct communication from the claimant on a form VA has prescribed for reporting changes in the status or number of the claimant’s dependents.
• Do not treat a VA Form 21-686c or VA Form 21-674 that an RO or call center employee completes and signs on a claimant’s behalf as communication from a third party simply because the claimant did not personally complete and sign the form.
• Call center employee signatures can be identified by the inclusion of either a station designation (such as 325/NCC) or the position title (such as Legal Administrative Specialist or Public Contact Representative) along with the employee's name.

5Determining Whether and How to Undertake Development When the Benefit Is Disability Compensation or DIC

This topic contains information for determining whether and how to undertake development when the benefit is disability compensation or DIC, including

• general information about claims development
• timing of development actions
• additional information/guidance relevant to claims development
• handling an incomplete
  • form, and
  • form when eligibility for additional benefits for dependents does not currently exist but a rating EP or claim for DIC is pending, and
• handling a September 2018 or later version of VA Form 21-686c that is
  • incomplete, and
  • incomplete when eligibility for additional benefits for dependents does not currently exist but a rating EP or claim for DIC is pending.

Revised March 13, 2025

VII.i.1.A.5.a#General Information About Claims Development

If a claimant submits a September 2018 or later version of VA Form 21-686c and fails to provide with the form all the evidence/information the form specifically instructs the claimant to provide, claims processors may not undertake development to obtain the missing evidence/information. Instead, they must follow the instructions in M21-1, Part VII, Subpart i, 1.A.5.f. The policy expressed in the previous paragraph does not relieve VA of its obligation to assist a claimant in obtaining documentary evidence (when required) of a life event (such as a birth, death, marriage, or divorce) if the claimant indicates an inability to provide it. Follow the instructions in the table below, taking into account the provisions ofM21-1, Part VII, Subpart i, 1.A.5.c, in those rare instances when VA receives a substantially complete September 2018 or later version of VA Form 21-686c , but

• evidence/information required to decide the claim is missing, and
• the form does not specifically instruct the claimant to provide the evidence/information that is missing

References: For more information on

• VA’s obligation to assist claimants in obtaining the documentary evidence described in this block, see M21-1, Part III, Subpart i, 2.A.1.a-e
• handling VA Form 21-686c that are not substantially complete, as defined in M21-1, Part I, Subpart i, 1.A.4.f, see Steps 2 through 8 of the table in M21-1, Part VII, Subpart i, 1.A.5.d, and
• requests for an application, see M21-1, Part II, Subpart iii, 2.G.1.

VII.i.1.A.5.b#Timing of Development Actions

To ensure the establishment of benefits in a timely manner, undertake any development necessary to establish entitlement to additional disability compensation or DIC for dependents during the initial development phase of claims processing when

• VA receives a claim for
  • SC and/or a higher disability rating from a Veteran, or
  • DIC from a surviving spouse
• the claimant reports the existence of one or more dependents on one of the forms listed in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, and
• evidence/information required to establish the Veteran’s relationship to the dependent(s) is not of record.

The upfront development referenced in the above paragraph must be undertaken, even if the claim is from a Veteran whose overall SC disability rating is currently less than 30 percent. Important:

• Disregard the instructions in this block if M21-1, Part VII, Subpart i, 1.A.5.a, prohibits claims processors from undertaking development.
• Follow the instructions in M21-1, Part VII, Subpart i, 1.C.1.d, if
  • the claimant is a Veteran who is eligible for additional compensation for dependents by virtue of a rating decision that is awaiting promulgation
  • the upfront development described in the opening paragraph of this block was mistakenly overlooked, and
  • either of the following is true
  • an EP 130 is not pending (because, for example, an EP 010 or 110 is concurrently pending), or
  • one of the ROs/restricted access claim centers (RACCs) identified in M21-1, Part II, Subpart ii, 2.B.1.b, is promulgating the rating decision in connection with a special mission or under a special circumstance.

VII.i.1.A.5.c#Additional Information/Guidance Relevant to Claims Development

This block contains additional information/guidance claims processors must consider in those situations in which it is appropriate to undertake development.

• Avoid unnecessary development and piecemeal development, as such actions
  • impose an unwarranted burden on claimants, and
  • delay claims processing.
• Do not undertake development for information or evidence without first ascertaining whether or not it is already of record.
• As explained in M21-1, Part VII, Subpart i, 1.B.1, every eight years, VA requires Veterans in receipt of disability compensation to verify the status of dependent(s). Accordingly, information that is already of record regarding the status of the dependent(s) of a Veteran is considered valid for the purpose of making entitlement determinations for up to eight years from the date VA received it. (The age of information of record is measured from the date VA received it to the current date.)

VII.i.1.A.5.d#Handling an Incomplete Form

The form a claimant uses to initiate the process of adding a dependent to an award must be substantially complete, as defined in M21-1, Part I, Subpart i, 1.A.4.f.A form may be substantially complete but fail to provide all the evidence/information VA requires to add a dependent to a claimant’s award. Follow the instructions in the table below when

• VA receives one of the forms identified in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, that is incomplete in any way , and
• the benefit at issue is disability compensation or DIC.

Exceptions:

• Do not treat a form as incomplete, for the purpose of development, if a claimant fails to provide
  • the name of the State in which an event (such as the birth of a child or a marriage) took place, when the city in which the event took place is well known (such as Atlanta or Chicago)
  • required information (such as the date of birth) on the form, when the missing information is shown on documentary evidence (such as a birth certificate) the claimant submits in support of the claim or is already of record, or
  • the last name of the current spouse.
• If the incomplete form is a September 2018 or later version of VA Form 21-686c,
  • disregard the instructions in the table below, and
  • follow the instructions in M21-1, Part VII, Subpart i, 1.A.5.f.
• If the form the claimant submitted requires the claimant to provide the number of prior marriages for the spouse, do not treat the form as incomplete if the claimant fails to provide the number, unless
  • there is reason to question the number of prior marriages the claimant and the spouse had
  • there is a conflict regarding the marital history the claimant reported that having the number of prior marriages would resolve, or
  • there is a reasonable indication of fraud or misrepresentation of the relationship in question.
• Follow the instructions in M21-1, Part VII, Subpart i, 1.A.4.c, instead of the instructions in the table below or the instructions in M21-1, Part VII, Subpart i, 1.A.5.f if the claimant is a Veteran whose overall SC disability rating is less than 30 percent and no rating EP is pending.

Important: The instructions in the table below were written based on an assumption the claimant is a Veteran with a running award of disability compensation based on an overall SC disability rating of at least 30 percent or a surviving spouse with a running award of DIC. If this is not the case, but a rating EP or claim for DIC is pending,

• stop at Step 10 of the table below, and
• follow the instructions in M21-1, Part VII, Subpart i, 1.A.5.e.

Important: If a claimant is eligible for additional benefits for a dependent but VA denies entitlement because the claimant failed to provide the evidence/information VA requested,

• inform the claimant that unless VA receives the evidence/information required to add the dependent within one year of the decision notice, VA cannot pay benefits for the dependent based on the present claim, and
• instruct the claimant to complete VA Form 20-0995, Decision Review Request: Supplemental Claim , and return it with the missing evidence/information.

Reference : For more information on preparing decision notices, see M21-1, Part VI, Subpart i, 1.B.

Reference: For more information on handling an incomplete application, see 38 U.S.C. 5102(b) and (c).

VII.i.1.A.5.e#Handling an Incomplete Form When Eligibility for Additional Benefits for Dependents Does Not Currently Exist But a Rating EP or Claim for DIC Is Pending

After taking the action described in Step 10 of the step-action table in M21-1, Part VII, Subpart i, 1.A.5.d, follow the instructions in the table below under either of the following situations:

• eligibility for additional compensation for a dependent(s) does not currently exist because the Veteran has no SC disabilities or the overall SC disability rating is less than 30 percent, but a rating EP is pending, or
• entitlement to DIC does not currently exist, but a claim for entitlement is pending.

Important: If a claimant is eligible for additional benefits for a dependent but VA denies entitlement because the claimant failed to provide the evidence/information VA requested,

• inform the claimant that unless VA receives the evidence/information required to add the dependent within one year of the decision notice, VA cannot pay benefits for the dependent based on the present claim, and
• instruct the claimant to complete VA Form 20-0995 and return it with the missing evidence/information.

Reference: For more information on preparing decision notices, see M21-1, Part VI, Subpart i, 1.B.

VII.i.1.A.5.f#Handling a September 2018 or Later Version of VA Form 21-686c That Is Incomplete

Follow the steps in the table below when VA receives a September 2018 or later version of VA Form 21-686c that is incomplete in any way.Important:

• In those rare instances when VA Form 21-686c does not ask the claimant for all the evidence/information VA requires to determine entitlement to additional benefits for dependents, and the claimant fails to submit such evidence/information,
• disregard the instructions in the table below, and
• follow the instructions in the applicable row of the table in M21-1, Part VII, Subpart i, 1.A.5.a.
• The instructions in the table below were written based on an assumption the claimant is a surviving spouse with a running award of DIC or a Veteran with a running award of disability compensation based on an overall SC disability rating of at least 30 percent. If this is not the case, but a claim for DIC or SC and/or a higher disability rating is pending, follow the instructions in M21-1, Part VII, Subpart i, 1.A.5.g.

References: For more information on

• preparing decision notices, see M21-1, Part VI, Subpart i, 1.B, and
• requesting documentary evidence of a life event from custodians of public records, see M21-1, Part III, Subpart i, 2.A.1.e.

VII.i.1.A.5.g#Handling a September 2018 or Later Version of VA Form 21-686c That Is Incomplete When Eligibility for Additional Benefits for Dependents Does Not Currently Exist But a Rating EP or Claim for DIC Is Pending

Follow the steps in the table below when

• VA receives a September 2018 or later__version of VA Form 21-686c that is incomplete in any way
• the claimant is a
  • Veteran that is not eligible for additional compensation for dependents because
    • there are no SC disabilities, or
    • the overall SC disability rating is less than 30 percent, or
  • surviving spouse that is not currently entitled to DIC, and
• a claim for one of the following is currently pending:
  • SC and/or a higher disability rating, or
  • entitlement to DIC.

Important: In those rare instances when VA Form 21-686c does not ask the claimant for all the evidence/information VA requires to determine entitlement to additional benefits for dependents, and the claimant fails to submit such evidence/information,

• disregard the instructions in the table below, and
• follow the instructions in the applicable row of the table in M21-1, Part VII, Subpart i, 1.A.5.a.

Important: If a claimant is eligible for additional benefits for a dependent but VA denies entitlement because the claimant failed to provide the evidence/information VA requires to recognize an individual as a dependent,

• inform the claimant that unless VA receives the missing evidence/information within one year of the decision notice, VA cannot pay benefits for the dependent based on the present claim, and
• instruct the claimant to complete VA Form 20-0995 and return it with the evidence/information that is missing for the remaining dependent(s).

Reference: For more information on preparing decision notices, see M21-1, Part VI, Subpart i, 1.B.

6Determining Whether and How to Undertake Development When the Benefit Is Pension

This topic contains information for determining whether and how to undertake development when the benefit is pension, including

• general information about claims development
• handling an incomplete form
  • pension, and
  • when entitlement to pension has not been established, but a claim is pending, and
• handling a September 2018 or later version of VA Form 21-686c that is
  • incomplete, and
  • incomplete when basic entitlement to pension exists but no award is running.

Revised March 13, 2025

VII.i.1.A.6.a#General Information About Claims Development

If a claimant submits a September 2018 or later version of VA Form 21-686c and fails to provide with the form all the evidence/information the form specifically instructs the claimant to provide, claims processors must follow the instructions in the table in M21-1, Part VII, Subpart ii, 1.A.6.d. Claims processors may not undertake development to obtain the missing evidence/information, except for the telephone development (to obtain income/net worth information) described in

• Step 4 of the table in M21-1, Part VII, Subpart i, 1.A.6.d, and
• Step 2 of the table in M21-1, Part VII, Subpart i, 1.A.6.e.

The policy expressed in the previous paragraph does not relieve VA of its obligation to assist a claimant in obtaining documentary evidence (when required) of a life event (such as a birth, death, marriage, or divorce) if the claimant indicates an inability to provide it. In those rare instances when VA receives a substantially complete September 2018 or later version of VA Form 21-686c , evidence/information required to decide the claim is missing, and the form does not specifically instruct the claimant to provide the evidence/information that is missing, claims processors must follow the instructions in the table below, taking into account the provisions ofM21-1, Part VII, Subpart i, 1.A.5.c.

References: For more information on

• VA’s obligation to assist claimants in obtaining the documentary evidence described in this block, see M21-1, Part III, Subpart i, 2.A.1.a-e
• handling VA Forms 21-686c that are not substantially complete, as defined in M21-1, Part I, Subpart i, 1.A.4.f, see Steps 2 through 9 of the table in M21-1, Part VII, Subpart i, 1.A.5.d, and
• requests for an application, see M21-1, Part II, Subpart iii, 2.G.1.

VII.i.1.A.6.b#Handling an Incomplete Form – Pension

The form a claimant uses to initiate the process of adding a dependent must be substantially complete, as defined in M21-1, Part I, Subpart i, 1.A.4.f. A form may be substantially complete but fail to provide all the evidence/information VA requires to add a dependent to a claimant’s award. Follow the instructions in the table when

• VA receives one of the forms identified in the last row of the table in M21-1, Part II, Subpart iii, 1.A.1.a, that is incomplete in any way , and
• the benefit at issue is pension.

Exceptions:

• Do not treat a form as incomplete, for the purpose of requiring development, if a claimant fails to provide
  • the name of the State in which an event (such as the birth of a child or a marriage) took place, when the city in which the event took place is well-known (such as Atlanta or Chicago)
  • required information (such as the date of birth) on the form, when the missing information is shown on documentary evidence (such as a birth certificate) the claimant submits in support of the claim, or
  • the last name of the current spouse.
• If the incomplete form is a September 2018 or later version of VA Form 21-686c,
  • disregard the instructions in the table below, and
  • follow the instructions in M21-1, Part VII, Subpart i, 1.A.6.d.
• If the form the claimant submitted requires the claimant to provide the number of prior marriages for the spouse, do not treat the form as incomplete if the claimant fails to provide the number, unless
  • there is reason to question the number of prior marriages the claimant and spouse had
  • there is a conflict regarding the marital history the claimant reported that having the number of prior marriages would resolve, or
  • there is a reasonable indication of fraud or misrepresentation of the relationship in question.

Important: The instructions in the table below were written based on an assumption the claimant has a running award. If the claimant does not have a running award, but a claim for pension is pending,

• stop at Step 3 of the table below, and
• follow the instructions in M21-1, Part VII, Subpart i, 1.A.6.c.

Important: If a dependent was not added to a claimant’s award because the claimant failed to provide the evidence/information VA requested,

• inform the claimant that unless VA receives the missing evidence/information within one year of the decision notice, VA cannot add the child to the claimant’s award based on the present claim, and
• instruct the claimant to complete VA Form 20-0995 and return it with the missing information.

Reference: For more information on notifying claimants of a VA decision, see M21-1, Part VI, Subpart i, 1.B.

VII.i.1.A.6.c#Handling an Incomplete Form When Entitlement to Pension Has Not Been Established but a Claim Is Pending

After taking the action described in Step 3 of the table in M21-1, Part VII, Subpart i, 1.A.6.b, follow the instructions in the table below if entitlement to pension has not been established but a claim is pending.

Important: If VA denies entitlement to benefits because the claimant failed to provide the evidence/information VA requested,

• inform the claimant that unless VA receives the missing evidence/information within one year of the decision notice, VA cannot pay benefits based on the present claim, and
• instruct the claimant to complete VA Form 20-0995 and return it with the missing evidence/information.

Reference: For more information on preparing decision notices, see M21-1, Part VI, Subpart i, 1.B.

VII.i.1.A.6.d#Handling a September 2018 or Later Version of VA Form 21-686c That Is Incomplete – Pension

Follow the steps in the table below when

• VA receives a September 2018 or later version of VA Form 21-686c that is incomplete in any way , and
• the benefit at issue is pension.

Important:

• In those rare instances when VA Form 21-686c does not ask the claimant for all the evidence/information VA requires to add a claimed dependent to the claimant’s award, and such evidence/information is missing,
  • disregard the instructions in the table below, and
  • follow the instructions in the applicable row of the table in M21-1, Part VII, Subpart i, 1.A.6.a.
• The instructions in the table below were written based on an assumption the claimant has a running award. If basic entitlement to pension has not been established, but a claim for pension is pending, take only the actions described in Step 1 and (if applicable) Step 2 of the table below.

If decision makers ultimately determine basic entitlement to disability or survivor pension exists,

• disregard the remaining instructions in the table below, and
• follow the instructions in M21-1, Part VII, Subpart i, 1.A.6.e.

Reference: For more information on notifying claimants of a VA decision, see M21-1, Part VI, Subpart i, 1.B.

VII.i.1.A.6.e#Handling a September 2018 or Later Version of VA Form 21-686c That Is Incomplete When Basic Entitlement to Pension Exists but No Award Is Running

Follow the instructions in the table below if

• no award is currently running, but VA has determined basic entitlement to pension exists, and
• the claimant submitted a September 2018 or later version of VA Form 21-686c that is substantially complete but lacks the evidence/information VA requires to add the claimed dependent(s) to the claimant’s award.

Important : In those rare instances when VA Form 21-686c does not ask the claimant for all the evidence/information VA requires to add a claimed dependent to the claimant’s award, and such evidence/information is missing,

• disregard the instructions in the table below, and
• follow the instructions in the applicable row of the table in M21-1, Part VII, Subpart i, 1.A.6.a.

Reference: For more information on notifying claimants of a VA decision, see M21-1, Part VI, Subpart i, 1.B.

7Requirement for Disclosure of SSNs to VA

This topic contains information about the requirement that beneficiaries and claimants disclose to VA their SSN and the SSNs of dependents, including

• regulatory basis for requiring disclosure of SSNs
• why SSNs are important to VA
• nonresident aliens without SSNs
• relevance of the assignment of an individual tax identification number (ITIN)
• guidelines for requesting an SSN from a beneficiary or claimant
• requirement for an SSN for children
• determing the credibility of a statement that no SSN has been assigned or requested, and
• action to take following receipt of notice that no SSN has been assigned or requested.

Revised March 13, 2025

VII.i.1.A.7.a#Regulatory Basis for Requiring Disclosure of SSNs

38 CFR 3.216 requires beneficiaries and claimants to disclose to VA their Social Security number (SSN) and the SSNs of dependents as a condition of receiving or continuing to receive compensation or pension. Important:

• 38 CFR 3.216 does not require beneficiaries, claimants, or dependents to obtain an SSN to receive VA benefits if no SSN has been assigned.
• If an SSN has neither been assigned to nor requested for an individual, the claimant or beneficiary must attest to this fact in a certified statement.
• Neither a certified statement nor further development to obtain an SSN is necessary if a claimant or beneficiary indicates no SSN has been assigned to an individual because the individual is a nonresident alien, as referenced in M21-1, Part VII, Subpart i, 1.A.7.c.

Reference: For more information on the certified statement referenced in this block, see M21-1, Part VII, Subpart i, 1.A.7.g.

VII.i.1.A.7.b#Why SSNs Are Important to VA

SSNs enable VA to conduct data exchanges with other agencies. These data exchanges

• provide VA with important information, such as verified Social Security income
• allow VA to conduct independent verification of a claimant’s income using Federal tax information, and
• help minimize overpayments.

VII.i.1.A.7.c#Nonresident Aliens Without SSNs

Many nonresident aliens do not have SSNs, and VA does not require an SSN to be obtained. Accordingly, it is unnecessary to request an SSN (or a certified statement indicating that no SSN has been assigned or requested) for an individual who

• has no SSN
• is not a U.S. citizen, and
• resides outside
  • the U.S.
  • the Commonwealth of Puerto Rico
  • the Virgin Islands
  • American Samoa
  • Guam, or
  • the Northern Marianas.

VII.i.1.A.7.d#Relevance of the Assignment of an ITIN

Upon receipt of notice that an individual with no SSN has an individual tax identification number (ITIN), make no further attempts to obtain

• that individual’s SSN, or
• a certified statement that no SSN has been requested for or assigned to that individual.

Note: The assignment of an ITIN to an individual by the Internal Revenue Service is an indication that

• no SSN has been assigned to that individual, and
• that individual is not eligible for an SSN.

VII.i.1.A.7.e#Guidelines for Requesting an SSN From a Beneficiary or Claimant

Follow the instructions in the table below for requesting an SSN from a beneficiary or claimant.

Notes:

• Follow the due process procedures discussed in M21-1, Part I, Subpart i, 1.B, before reducing or discontinuing an award because a beneficiary failed to provide VA with an SSN.

• Per 38 CFR 3.500(w), the effective date of a reduction in or discontinuance of an award because a beneficiary failed to provide an SSN is the last day of the month (first day of the month for award-adjustment purposes) following a 60-day period that begins on the date VA requested the SSN.

VII.i.1.A.7.f#Requirement for an SSN for Children

Beneficiaries/claimants must provide an SSN (or a certified statement that no SSN has been assigned or requested) for all children, regardless of

• a child’s age, or
• whether the child is the claimant or a dependent.

VII.i.1.A.7.g#Determining the Credibility of a Statement That No SSN Has Been Assigned or Requested

Absent evidence to the contrary, accept as credible a statement from a beneficiary or claimant that no SSN has been assigned or requested, unless the individual who reportedly has no SSN

• receives Social Security or other Federal benefits, or
• has an account at a bank or other financial institution.

When the conditions described in the above bullets exist, follow the instructions in the table below. Important:

• Oral certification that no SSN has been assigned or requested is acceptable only if the individual who reportedly has no SSN is a non-resident alien, as referenced in M21-1, Part VII, Subpart i, 1.A.7.c. In all other cases, a written and signed statement from the claimant or beneficiary is required.
• Beneficiaries/claimants may submit the certified statement referenced in this block electronically, in person, or by mail.

Important : When preparing the decision notice referenced in the preceding bullet,

• inform the claimant that unless VA receives the statement from SSA within one year of the decision notice, VA cannot award benefits based on the present claim, and
• instruct the claimant to complete VA Form 20-0995 and return it with the statement.

Reference: For more information on preparing decision notices, see M21-1, Part VI, Subpart i, 1.B.

VII.i.1.A.7.h#Action to Take Following Receipt of Notice That No SSN Has Been Assigned or Requested

Follow the instructions in the table below following receipt of notice that no SSN has been assigned to or requested for a beneficiary or a dependent.

8Medical Records That Reveal the Existence of a Dependent That Is Not on a Veteran’s Award

This topic contains information about medical records that reveal the existence of a dependent that is not on a Veteran’s award, including

• action to take when medical records reveal the existence of a dependent that is not on a Veteran’s award, and
• assigning an effective date based on information about dependents that VA discovers in medical records.

Revised February 15, 2022

VII.i.1.A.8.a#Action to Take When Medical Records Reveal the Existence of a Dependent That Is Not on a Veteran’s Award

Review of a Veteran’s medical records will occasionally reveal the existence of a spouse or child that has not been added to a Veteran’s award. Upon discovering such information, follow the instructions in the table below. Important: RO employees should not routinely review medical records for the sole purpose of identifying dependents that have not been added to a Veteran’s award.

VII.i.1.A.8.b#Assigning an Effective Date Based on Information About Dependents That VA Discovers in Medical Records

When a Veteran returns the VA Form 21-686c that VA sent in accordance with the instructions in M21-1, Part VII, Subpart i, 1.A.8.a, determine whether VA may recognize the individual named on the form as the Veteran’s dependent. If VA can recognize as a dependent the individual named on the form, add the individual to the Veteran’s award effective the earlier of the following dates:

• the first of the month following the month VA received the signed and completed VA Form 21-686c, or
• the first of the month following the date of the event that allowed the Veteran to add a dependent to the award if the Veteran submitted a signed and completed VA Form 21-686c within one year of that date.

Example: An “event,” for the purpose of this block, might include

• marriage
• birth of a child, or
• the assignment of an overall SC disability rating of at least 30 percent.

Reference: For more information on determining the proper effective date for adding a dependent to a Veteran’s award, see

• M21-1, Part VII, Subpart i, 1.C.2 (awards of disability compensation only), and
• 38 CFR 3.401(b).